The Centers for Medicare and Medicaid Services (CMS) released the Medicare Access and CHIP Reauthorization Act (MACRA) final rule for 2018.
In the rule, CMS outlines their expectations of practices participating in MACRA this January.
Here’s our summary of what is included:
Changes in MIPS
- Stronger Improvement Activities requirements for multi-practice entities. To receive auto-credit for Improvement Activities, the final rule stipulates that 50% of practices within a Tax Identification Number (TIN) must have recognition for all practices to receive auto-credit for Improvement Activities.
- What This Means for You: Previously only 1 practice within a TIN needed recognition. Now, if you’ll be applying under a multi-practice entity, know that 50% must be recognized. If this isn’t possible, you can decide to report individually rather than as a group under MIPS.
- Cost will count for 10% in 2018. Initially, CMS did not incorporate Cost into the MIPS equation for 2018 report year. But now, cost will be factored into the equation starting January.
- What This Means for You: CMS calculates cost scores for each practice based on Medicare Spending per Beneficiary (MSPB) and total per capital cost measures. The practice is not responsible for sending anything to CMS regarding the cost section, but be aware that it will be included in your bottom line for 2018 report year (2020 payment year). This also means the Quality category is being reduced to 50% of the total MIPS score.
- More smaller practices exempt from MIPS. In 2018, CMS expands the money and patient thresholds.
- What This Means for You: If you are a MIPS-eligible clinician or group with less than or equal to $90,000 in Part B charges or care for 200 or less beneficiaries, then you are exempt from reporting performance in 2018. This is up from $30,000 or 100 patients in 2017.
- Virtual Groups begin in 2018. CMS introduces virtual groups, which allow small practices to join together to expand their ability to improve quality and have sufficient patients for quality measurement.
- What This Means for You: Solo practitioners and small practices have the choice to form or join a virtual group to participate with other practices. However, CMS did not take our suggestions, and the rule prevents the smallest practices from joining virtual groups by defining “low-volume” practices as ineligible for MIPS. (Practices who want to join a virtual group need to meet the money and patient thresholds to be eligible for MIPS). You can find more information about virtual groups here.
- Auto-credit for NCQA Patient Centered Connected Care practices.
- What This Means for You: If you’re an NCQA-Recognized Patient-Centered Connected Care practice, you receive auto-credit for the Advancing Care Information (ACI) category. The Connected Care program brings urgent, retail and other stand-alone clinics into the medical neighborhood. This means Connected Care practices get an automatic 25% towards their ACI score. Connected Care practices get credit for 3 Advancing Care Information measures (Provide Patient Access, Patient-Specific Education and Patient-Generated Data), which earn up to 10 points each toward the total ACI score.
- Bonus points for using 2015 edition Certified Electronic Health Record Technology (CEHRT) in ACI
- What This Means for You: Practices can use either 2014 or 2015 Edition CEHRT. However, if you use ONLY the 2015 Edition CEHRT, you will receive a 10% bonus towards your overall ACI score.
- More bonus points included. CMS offers bonus points for treating complex patients and for small practices.
- What This Means for You: For small practices, CMS gives 5 bonus towards your overall score. For practices treating complex patients, CMS applies up to 5 bonus points to your overall score.
- CMS expresses interest in NCQA’s eMeasure Certification program to strengthen the reliability and validity of electronic systems.
- What This Means for You: There are no specific requirements or auto-credit for using a certified EHR vendor, but since CMS notes their interest, you may benefit from using a certified EHR. You can see our list here.
Changes in APMs
- More APMs being considered. In 2018, CMS will hold a Medicare Advantage Alternative Payment Models (APMs) demonstration. This change is an important step towards harmonizing APMs from all payers, which greatly reduces burden on clinicians who now must meet different requirements for different insurers.
- What This Means for You: If you’re a Medicare Advantage plan, you count as a MACRA APM. Since many Medicare Advantage plans already have robust APMs in place that are already resulting in improved cost and quality for their enrollees, allowing this to count in MACRA reduces some of your reporting burden.
CMS allows comments on the final rule. If you want to learn more about the final rule, comment below and we’ll answer your questions. Stay tuned to the NCQA blog and the MACRA toolkit for more details on MACRA.